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#2132496 - 05/31/17 04:07 PM What address do you use for a business on a CTR?
Amandak Offline
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Joined: Jul 2013
Posts: 80
Wisconsin
What address to you use for a business on a CTR, corporate address or the local store address?

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#2132518 - 05/31/17 05:33 PM Re: What address do you use for a business on a CTR? Amandak
RockChucker, CAMS Offline
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Posts: 1,655
The Country
We typically ask for the address associated with the business. We are indifferent if it is for the corporate office or the local office. The majority of the time it is the same address, they only have one location.
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#2132530 - 05/31/17 06:14 PM Re: What address do you use for a business on a CTR? Amandak
Daisy Doodle Offline
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Southern U.S.
I prefer the local store location if feasible. If there are multiple locations under the same corporation, the corporate address is fine.

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#2132588 - 05/31/17 08:45 PM Re: What address do you use for a business on a CTR? Amandak
Sunshine Lady Offline
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Posts: 629
We use the store address.
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#2132613 - 06/01/17 09:22 AM Re: What address do you use for a business on a CTR? Amandak
Elwood P. Dowd Offline
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Assuming "the business" is not a sole proprietorship, use the address that produced the cash.
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#2132627 - 06/01/17 01:02 PM Re: What address do you use for a business on a CTR? Amandak
thomasj Offline
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Pennsylvania
In my experience, if I have an account for one location of Acme Convenience Stores, Inc. I will use the physical local address of that location. If I have accounts for three locations of Acme Convenience Stores, Inc. (assuming they are all under the same corporate EIN) I will use the physical address of the home office for the aggregate CTR.
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#2132813 - 06/02/17 08:22 AM Re: What address do you use for a business on a CTR? thomasj
Elwood P. Dowd Offline
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The suggestion to use the address that produced the cash originated with the Helpline and has been confirmed since.
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#2240463 - 07/31/20 02:05 PM Re: What address do you use for a business on a CTR? Elwood P. Dowd
ksbanker Offline
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Joined: May 2018
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In light of FIN-2020-R001 is this still correct? I am thinking it is, but a consultant seemed to think in the case of a CTR involving a small business with 2 locations, we should complete two Part I's. One for the "headquarters" and the other for the location where the cash originated.

Reading FIN-2020-R001 it would seem we are to have a Part I for the "home office" and a second Part I for the location where the cash originated.

Other's think this only applies for an aggregated CTR. What are your thoughts?

For reference:

"When a CTR is prepared on a legal entity such as a partnership, incorporated business, or
limited liability company, a Part I section should be prepared containing the home office/
headquarters data (address, telephone number, identification number, etc.) of the entity. When
multiple entity locations are involved in an aggregated CTR, a separate Part I section should be
prepared for each location involved. Each additional Part I section should include the entity’s
legal name in Item 4 and alternate name, if any, in Item 8. Each additional Part I section will
include the location’s address along with all other location or entity data applicable to that
location. The amount and account number(s) entered in Item 21 “Cash in amount…” or Item
22 “Cash out amount…” will be the amount and account number(s) associated with the specific
location. The initial Part I section on the entity home office/headquarters will show the total
amount and all account numbers involved in Item 21 or 22. When there are multiple DBA
names involved in the transaction, Item 8 “Alternate name” should be left blank in the entity
home office Part I section. When the entity home office address is the same as the transaction
location, only a home office Part I section should be prepared."

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#2240557 - 08/03/20 07:29 PM Re: What address do you use for a business on a CTR? Amandak
John Burnett Offline
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Cape Cod
If you implemented that guidance, you should be following it correctly, but do note that FinCEN has suspended that ruling in response to the pandemic until further notice. Of course, they closed that notice with "Those financial institutions that have already made the necessary changes to comply with the 2020 Ruling need not revert to prior practice, and may report CTRs in accordance with the now-suspended ruling."

As to the ruling itself, it is unclear. On the one hand, it says that the part I entry should show the HQ address, email, phone number, etc. (to the extent you have such other contact info). Then it says that if multiple locations are involved, include a separate Part I for each location. So, taking the first requirement literally, I would say you only need one part I section, and use the HQ contact info, not the local store's.
Last edited by John Burnett; 08/05/20 03:38 PM.
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#2240666 - 08/05/20 03:46 PM Re: What address do you use for a business on a CTR? Amandak
John Burnett Offline
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John Burnett
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Cape Cod
How many banks have changed to using the headquarters address in a CTR rather than a local address (the address where the cash came from) when filing CTRs? Did the February 2020 ruling (now suspended) influence that change? Do we know what FinCEN wants?

We really don't know what will happen to FIN-2020-R001 once the COVID-19 emergency fades away. Given its track record on swift action, I don't think we'll see FinCEN address it right away. But if and when they do, we might get the same wording (with the existing ambiguities), a tweaked set of requirements, or outright rescission. It's anyone's guess.
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